Comment Letters

Comment Letters

*NEW* Academy Comments on CY 2015 MPFS Final RuleIn October CMS released the final rule for the 2015 Medicare Physician Fee Schedule (MPFS). In its 2015 MPFS Final Rule, CMS reiterated its proposal of a more transparent process for establishing PFS payment rates that will allow for more public input prior to finalizing rates. CMS finalized that 2016 will be a transition year during which they will propose values for new, revised, and potentially misvalued codes that they receive RUC recommendations in time for inclusion in the 2016 proposed rule. For all others, they will establish interim final values in the 2016 final rule as they have historically done. In addition, CMS finalized changes that increase values for rigid and transnasal esophagoscopy codes, expand quality reporting options for otolaryngologists, and that continue phasing in the Value Based Payment Modifier. Notably, CMS is finalizing its proposal to transform all 10- and 90-day global codes to 0-day global codes beginning in CY 2017, revising its proposed list of misvalued codes, and finalizing adjustments to malpractice RVUs among other initiatives.

Academy Submits Comments to CMS on CY 2015 MPFS Proposed RuleOn September 2nd, the Academy submitted comments to the Centers for Medicare & Medicaid Services (CMS) addressing several of their proposals in the CY 2015 Medicare Physician Fee Schedule (MPFS), including transitioning all 10- and 90-day global codes to 0-day global codes over a two year period, identifying approximately 80 codes as “potentially misvalued” and requiring review, and conducting the statutorily mandated update to malpractice RVUs. View the Comment Letter

Academy's Comment Letter on CY 2014 MPFS Final RuleThe Academy submitted comments to CMS by the January 27th deadline on the final rule for the CY 2014 Medicare Physician Fee Schedule. In the letter, the Academy addressed issues that affect Otolaryngology- Head and Neck Surgery. Click below to see the comment letter:

Academy's Comment Letters on CY 2014 MPFS and HOPPS/ASC Proposed RulesThe Academy submitted comments to CMS by the September 6th deadline on the proposed rules for the CY 2014 Medicare Physician Fee Schedule and the CY 2014 HOPPS/ASC Payments. In the letters, the Academy addressed issues that affect Otolaryngology- Head and Neck Surgery. Click below to see each comment letter:

The Academy submitted comments to CMS by the December 31st deadline on the final rules for the CY 2013 Medicare Physician Fee Schedule and the CY 2013 HOPPS/ASC Payments. In the letters, the Academy addressed issues that affect Otolaryngology-Head and Neck Surgery. Click below to see each comment letter:

On August 28th, 2012, we submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rules for the CY 2013 Medicare Physician Fee Schedule and CY 2013 HOPPS/ ASC Payment. In the letters, the Academy addressed issues that affect otolaryngology- head and neck surgery including quality reporting initiatives, the Sustainable Growth Rate (SGR), and Outpatient and Ambulatory Surgical Center payment. Click below to see each comment letter: